Under the updated Title II rule of the Americans with Disabilities Act (ADA), all public-facing digital services provided by state and local governments must comply with WCAG 2.1 Level AA accessibility standards. This includes digital tools used by public pension plans, from benefit statements and member portals to retirement calculators and mobile apps.
The first compliance deadline arrives in April 2026 for entities serving more than 50,000 people. A second deadline follows in April 2027 for smaller entities and special districts. These requirements apply to the full digital experience, not just new services or tools in development.
Any public pension plan offering digital services to members must ensure those services are accessible. That includes providing proper support for screen readers, enabling full navigation using only a keyboard, and ensuring that layouts are clear and consistent for people with cognitive or visual impairments. It also means ensuring contrast ratios, resizable text and well-structured pages can be interpreted by assistive technologies.
In essence, the Act aims to remove barriers so that more people, regardless of ability, can access and understand their pension benefits.
For many plans, particularly those using legacy systems or heavily customized platforms, the ADA update poses a real challenge. Older tools were rarely designed with accessibility in mind, and retrofitting those tools can be complex, costly and slow.
At the same time, the ADA Title II update creates an opportunity to improve the digital experience for plan members. Members are already asking for greater clarity and easier access. Making tools more inclusive can help deliver that. It’s not just members that benefit. Plans that improve digital accessibility can benefit from fewer support queries, better understanding of benefits among members and higher overall satisfaction with online services. Meeting accessibility compliance regulations in turn help make digital services better for everyone.
For many organizations, the first step is a clear-eyed assessment of where things stand today. That includes testing whether portals, statements and self-service tools meet WCAG 2.1 Level AA standards, both through automated tools and manual testing using assistive technologies.
If you work with a vendor, ask whether accessibility is built into their development process. Confirm whether their platforms meet compliance standards, whether they can deliver updates without disruption and how they plan to support your organization as regulations continue to evolve.
Plans that use modular, cloud-based platforms with regular release cycles will generally find it easier to keep pace. These platforms are often better positioned to integrate accessibility updates without full rebuilds or major interruptions.
Crucially, accessibility should not be treated as an afterthought. It should be built into broader modernization strategies. As pension plans continue to upgrade systems and digital tools, accessibility must be part of that conversation. For many members, these tools are the primary way they engage with their retirement benefits. Excluding any group, even unintentionally, is no longer acceptable.
The new ADA requirements are a catalyst for progress. Whether you are planning a full system replacement or looking to optimize your current platform, now is the time to take accessibility seriously. It is not just about meeting a standard. It is about delivering a better service for everyone.